UC Comment Letters

This comment letter responds to the Department of Commerce Bureau of Industry and Security (BIS)'s proposed amendments to the Export Administration Regulations originally issued on July 29, 2024. UC supports BIS’s proposed EAR amendments aimed at clarifying export controls and protecting privacy against unjustified government use of facial recognition and other mass-surveillance technologies. UC endorses AUECO and COGR recommendations for clearer Foreign-Security End User provisions and a more specific definition of facial recognition systems so regulators and institutions can better identify high-risk uses while excluding low-risk organizations and activities.